Whistleblower

1. Introduction
All employees of the M K Land Holdings Berhad (“M K Land”) and its subsidiaries (“the Group”) play an important part in maintaining the highest level of corporate ethics within the Group, and have a professional responsibility to disclose any known malpractices or wrongdoings (hereon referred to as “Concerns”).

2. Scope
This Policy applies to all matters involving M K Land and the Group’s employees and any other stakeholders of the Group including consultants, vendors, independent contractors, external agencies and/or any other party with business relationship with the Group.

Should it be determined during the preliminary investigation that the matter disclosed does not fall within the scope of this Policy, such matters will be transferred and dealt with by the appropriate personnel of the relevant department for appropriate procedures and actions to be taken.

3. Safeguards
A person or entity making a protected disclosure is commonly referred to as a “Whistleblower”. Whistleblowers provide initial information related to a reasonable belief that an improper activity has occurred.

Whistleblowers are protected against being dismissed or penalised provided that the whistleblowing is done in good faith. It is to be noted that any person who has not acted in good faith shall not be entitled to any protection under this Policy.

If allegations are proven to be malicious or founded on bad faith, parties responsible may be subject to appropriate action, including but not limited to legal action, where applicable and MK Land shall consider mitigating circumstances if the Whistleblower himself / herself is involved in the activity that he / she reports.

4. Protection from Retaliation
Any party that retaliates against someone who has reported a wrongdoing in good faith may be subject to appropriate action, up to and including legal action, where applicable.

5. Confidentiality
Every effort shall be made to treat the Whistleblower’s identity with appropriate regard for confidentiality. Disclosures received under anonymity will not be entertained to prevent false malicious reporting, exploitation and victimization. The Group gives the assurance that it shall not reveal the identity of the Whistleblower to any third party not involved in the investigation or prosecution of the matter. The only exception to this assurance relates to an overriding legal obligation to breach confidentiality. The Group is obligated to reveal confidential information relating to a whistle-blowing report, if ordered to do so by a court of law.

6. Types of Improper Conduct
A complaint on improper conduct, unethical behavior, malpractices, illegal acts or criminal offence shall include, but not limited to the following:

1. Bribery, corruption or money laundering:
2. Criminal breach of trust, abuse of power and position or blackmail;
3. Fraud, -illicit and corrupt practices;
4. Conflict of interest;
5. Sexual harassment;
6. Misappropriation of assets or resources;
7. Unauthorized disclosure or misuse of confidential information;
8. Acts or omissions which are deemed to be against the best interests of the Company;
9. Non-compliance with the Company’s regulations, policies and procedures; and
10. Non-compliance with laws, regulations, requirements of statutory bodies or public policies.

7. Procedures

7.1 Process for Disclosure

I) Impropriety
This policy covers improprieties or irregularities, suspected fraud or criminal offences, breach of confidentiality and failure to comply with statutory or regulatory requirements.

II) Reporting
Managers, officers and employees in supervisory roles shall report to the reporting person(s) on any allegations of suspected improper activities. Such disclosures, including those relating to financial reporting, unethical or illegal conduct, may be reported directly to:

Chairman, Audit and Risk Management Committee

M K Land Holdings Berhad,
No.19 Jalan PJU 8/5H,
Perdana Business Centre,
Bandar Damansara Perdana,
47820 Petaling Jaya,
Selangor
Email: chairman.armc@mkland.com.my

Employment-related concerns may be reported to:
Head of Human Resources
MK Land Holdings Berhad,
No. 19 Jalan PJU 8/5H,
Perdana Business Centre,
Bandar Damansara Perdana,
47820 Petaling Jaya,
Selangor
Email: HR.WhistleB@mkland.com.my

Disclosures should be in writing and forwarded in a sealed envelope to the above mentioned contact person(s) labelling with a legend such as “To be opened by the Chairman, Audit and Risk Management Committee or Head of Human Resources only”.

III) The action taken by the Group in response to a report of Concern under this policy shall depend on the nature of the concern. The Chairman, Audit and Risk Management Committee and/or the Group CEO shall receive information on each report of Concern and follow-up information on actions taken.

7.2 Investigator

The Internal Auditor shall be the named Investigator unless the Chairman, Audit and Risk Management Committee and/or the Group CEO assigns / appoints another Investigator. Investigators must be impartial and independent of all parties concerned.

The Investigator is required to report all Concerns raised, the status of all pending and on-going investigations, and any action taken or to be taken as a result of the investigations, to the Senior Independent Director and/or the Group CEO.

7.3 Inquiries

Initial inquiries shall be made to determine whether an investigation is appropriate, and the form that it should take. Some Concerns may be resolved without the need for investigation.

If an investigation leads the Investigator to conclude that a crime has probably been committed, the results of the investigation shall be reported to the police or other appropriate law enforcement agency.

If an investigation leads the Investigator to conclude that the suspect has engaged in conduct that may be a violation of the Group’s Code of Ethics or Conduct, the results of the investigation shall be reported to the Head of Human Resources and/or the Group CEO in accordance with the applicable procedures for company conduct and the administration of discipline. Any charges of misconduct brought as a result of an investigation under this policy shall comply with established disciplinary procedures.

8. Monitoring and Review of Policy
The Board should ensure that the policy meets the objectives of relevant legislations and remain effective for the Group.

This policy shall be reviewed annually by the Board and, as and when the need arises.

Policy reviewed and adopted on 19 October 2023